Practice Areas

U.S. persons engaged in international trade may be subject to U.S. government regulation even when a transaction occurs entirely outside the geographic boundaries of the United States. The Foreign Corrupt Practices Act (“FCPA”) prohibits U.S. companies from making payments to foreign government officials for the purpose of influencing their actions. An exception to the FCPA's broad prohibition permits minor payments to expedite or facilitate “routine governmental action.” U.S. boycott/antiboycott laws restrict a U.S. company's ability to comply with international boycotts imposed by foreign governments.

When an international emergency threatens the security of the United States, the President may impose a partial or total embargo on trade with a hostile foreign country and/or its nationals. These embargoes, administered principally by the Treasury Department's Office of Foreign Assets Control, can cause severe disruptions in international trade. The United States currently maintains embargoes of varying degrees on trade with several countries, including Cuba, North Korea, Syria, Sudan and Iran. deKieffer & Horgan counsels U.S. and foreign companies on compliance with the FCPA and the various OFAC regulations and represents them before these agencies in obtaining rulings or licenses or in defending against allegations of wrong-doing.